NLP-based Automated Compliance Checking of Data Processing Agreements against GDPR
Authors: Orlando Amaral, Muhammad Ilyas Azeem, Sallam Abualhaija, Lionel C Briand
AI-generated Key Points
- Authors address regulatory challenges posed by GDPR in Europe
- Proposed solution aims to streamline compliance checking process mandated by GDPR for software development involving personal data processing
- Approach leverages NLP technologies and collaboration with legal experts
- System extracts relevant requirements from GDPR provisions and creates glossary table defining key legal concepts
- Automated system successfully identifies violations and satisfied requirements with high precision and recall rates
- Demonstrates significant improvements in accuracy compared to baseline NLP tools
- System's accuracy can be further enhanced with limited manual verification efforts
- Solution enhances efficiency in ensuring DPA compliance and showcases potential for technology-driven advancements in navigating complex regulatory landscapes like GDPR within software development processes.
Abstract: Processing personal data is regulated in Europe by the General Data Protection Regulation (GDPR) through data processing agreements (DPAs). Checking the compliance of DPAs contributes to the compliance verification of software systems as DPAs are an important source of requirements for software development involving the processing of personal data. However, manually checking whether a given DPA complies with GDPR is challenging as it requires significant time and effort for understanding and identifying DPA-relevant compliance requirements in GDPR and then verifying these requirements in the DPA. In this paper, we propose an automated solution to check the compliance of a given DPA against GDPR. In close interaction with legal experts, we first built two artifacts: (i) the "shall" requirements extracted from the GDPR provisions relevant to DPA compliance and (ii) a glossary table defining the legal concepts in the requirements. Then, we developed an automated solution that leverages natural language processing (NLP) technologies to check the compliance of a given DPA against these "shall" requirements. Specifically, our approach automatically generates phrasal-level representations for the textual content of the DPA and compares it against predefined representations of the "shall" requirements. Over a dataset of 30 actual DPAs, the approach correctly finds 618 out of 750 genuine violations while raising 76 false violations, and further correctly identifies 524 satisfied requirements. The approach has thus an average precision of 89.1%, a recall of 82.4%, and an accuracy of 84.6%. Compared to a baseline that relies on off-the-shelf NLP tools, our approach provides an average accuracy gain of ~20 percentage points. The accuracy of our approach can be improved to ~94% with limited manual verification effort.
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